Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Warranty provision computed on a scientific basis was treated as deductible where it reflected a present obligation from past events, was likely to result in an outflow of resources, and could be reliably estimated; reopening on the same record was quashed because it ignored the governing principle on deductible warranty liability and material already disclosed. Reopening over forfeited security deposits linked to C-Forms was also invalid because the assessee had already disclosed the customer-wise details and the use of the amounts to meet sales tax liability, so the attempt amounted only to a change of opinion. On both grounds, reassessment was set aside.
Warranty provision computed on a scientific basis was treated as deductible where it reflected a present obligation from past events, was likely to result in an outflow of resources, and could be reliably estimated; reopening on the same record was quashed because it ignored the governing principle on deductible warranty liability and material already disclosed. Reopening over forfeited security deposits linked to C-Forms was also invalid because the assessee had already disclosed the customer-wise details and the use of the amounts to meet sales tax liability, so the attempt amounted only to a change of opinion. On both grounds, reassessment was set aside.
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